Donald Trump's Complaint Against Attorney General Eric Schneiderman

New York State Joint Commission on Public Ethics 540 Broadway Plaza Albany, New York 12207 www.jcope.ny.gov 518-408-3976

SWORN

COMPLAINT

The Joint Commission on Public Ethics has jurisdiction

to

investigate potential violations of Public Officers Law §73, §73-a, §74,

Civil

Service Law §107 and Legislative Law article

1-A

as

they apply to state legislators, candidates for the Legislature

and

legislative employees,

as

well

as

the four statewide elected officials, candidates for those offices, executive branch state employees, certain political party chairs, and lobbyists

and

their clients.

COMPLAINANT

NAME

Donald

J

Trump and The Trump

Organization

ADDRESS

c/o

Stephen

B.

Meister,_Esq., Meister Seelig &

F~L~?

LLP

_._.

_.

CITY

STATE

ZIP

2

Grand Central Tower,

140

East

45th

Street,

19th

Floor,

New

York,

New

York

10017

TELEPHONE_ ll.J.L6S5-:l~_L

______________

_ _ _ _ _

EMAIL

.Q...n: @msf-Iaw.com

Please provide a statement

or

description of the alleged violation of Public Officers

Law

§73, §73-a, §74,

Civil

Service Law §107

or

Legislative Law article

1-A

including facts constituting a violation

of

the law(s) above, the identity of the individual(s)

at

issue and, if possible, a date, time, place of the alleged violation.

Also

note any documents or exhibits you

are

including to support the allegations. See

attached

Complaint.

.

_

Has

this

O atter~~en

r~ferred ~9~tly·q~h~r~~~JlCY?

0

Yes

IKl

No

If

yes

whic:h

~~em:Y?

II,--,-,~~.,-- '~~.,__.,__~_=:__-,.,..,...,.,..._,_-.,.,...--.,.,..._.,.,..._....,....,-~-,-----..l

Is

there

p.~nqi.~gl~g~r~ctiQ~Yq.~ar~a, it~:r~gf?

.

0

Yes

llilNO

If

E: S~

wh.ere?

As

detailed in the attached Complaint, the Trump Parties allege misconduct

by

New York State Attorney General Eric T. Schneidenllan preceding Mr. Schneidennan's filing

of

an action entitled People v. The Trump Entrepreneurial Initiative LLC et al. in

New

York County Supreme Court bearing Index Number 45146312013.

I

Donald I.

Trump •

being duly sworn, have

read

the

foregoing complaint in its entirety, including

any

additional pages,

and

to the

best

of

my

knowledge,

or

based

on information and belief, believe

it to

be true. I also

understand

the

of false information may constitute a crime punishable by fine

or

impris,on:menll>r Sworn to before me this

2nd

day of

PAGE_l_OF_ _

ALAN GARTEN

Notary Public, State

of

New

York

No. 02GA6021578

Qualified in Nassau County )

r

Commission Expires on March 15, 20

New York State Joint Commission on Public Ethics

54

Broadway Plaza Albany New York 12207 www.jcope.ny.gov

518·4 8·3976

SWORN

COMPL INT

DDITION L

P GE

PAGE_2_ F_2_

INJTIALS-,D=,,,- IT~_

BEFORE THE NEW YORK STATE JOINT COMMISSION ON PUBLIC ETHICS

DONALD

J

TRUMP

and

THE

TRUMP

ORGANIZATION, Complainants,

v

ERIC

T.

SCHNEIDERMAN

Respondent.

IN THE MATTER OF AN INVESTIGATION INTO APPARENT MISCONDUCT BY NEW YORK STATE ATTORNEY GENERAL ERIC T SCHNEIDERMAN

MEISTER SEELIG FEIN LLP 2 Grand Central Tower 140 East 45

th

Street,

19

th

Floor

New

York, N

ew York

10017 212) 655-3500

ttorneys

or

Complainants

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